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2013 (8) TMI 77 - GUJARAT HIGH COURTNotice u/s 148 - A.O. rejected assessee's objection to notice of reassessment - Held that:- impugned notice has been issued beyond a period of four years from the end of relevant assessment year - neither any order rejecting the petitioner's objection nor Revenue contends that the belief of the Assessing Officer that income chargeable to tax has escaped assessment, is based on any material outside of the record - full facts were there before the Assessing Officer in the form of declarations made in the returns filed as well as through correspondence during the course of scrutiny assessment. This therefore, is not a case where the assessee is stated to have failed to disclose truly and fully all material Acts necessary for assessment - Decided in favour of assessee.
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